Casinos operate under strict U.S. anti-money laundering rules, with FinCEN enforcing Title 31 requirements like CTRs, SARs, customer due diligence, and robust recordkeeping. While reporting has surged, actual enforcement has lagged, creating a concerning gap that undermines deterrence and accountability. With enforcement momentum returning in 2024 and higher expectations under the AML Act of 2020, casinos must treat BSA compliance as core, prioritizing accurate filings, strong controls, and a culture of vigilance.
Key insights:
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4 pillars of surveillance — Casinos operate under a comprehensive BSA and Title 31 anti-money laundering framework, anchored by four pillars that together create a surveillance network to detect and deter illicit activity.
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Significant gap in enforcement — Despite a massive surge in SAR filings, enforcement actions were virtually nonexistent, revealing a significant enforcement gap that undermines deterrence.
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Balancing regulatory rules and risk — Effective CTR and SAR practices are both a regulatory obligation and a risk signal: Strong, timely, accurate reporting and a compliance-first culture help avoid penalties and protect reputation, while weak programs invite costly, rigorous enforcement.
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Casino operators face increasingly rigorous anti-money laundering (AML) obligations under federal banking secrecy laws that require extensive reporting, customer monitoring, and record maintenance systems. These regulatory mandates, enforced by the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN), establish four core pillars of compliance: i) currency transaction reporting for cash activities exceeding $10,000; ii) suspicious activity reporting for potentially illicit behavior; iii) customer identification protocols; and iv) comprehensive recordkeeping standards.
While recent enforcement data reveals significant gaps between the volume of filed reports and actual regulatory actions, casinos must prioritize robust AML programs to avoid substantial penalties and reputational damage.
Under United States federal law, casinos operate within a stringent AML framework governed by Title 31 of the U.S. Code, commonly known as the Bank Secrecy Act (BSA). FinCEN serves as the primary regulator, enforcing comprehensive requirements designed to prevent casinos from becoming conduits for financial crimes.
The 4 pillars of casino AML compliance
1. Currency Transaction Reports (CTRs)— These reports form the foundation of casino reporting obligations. When a customer’s combined cash transactions exceed $10,000 in a single day, casinos must electronically file a detailed report within 15 calendar days. These reports capture essential customer information, such as name, address, Social Security number (SSN), and other identification details.
2. Suspicious Activity Reports (SARs)— These reports, filed with FinCEN, target potentially illicit behavior. For transactions of $5,000 or more that raise red flags, casinos must file comprehensive SARs within 30 days. Crucially, customers are never informed of these confidential reports.
3. Customer identification and due diligence— These requirements ensure casinos know who they’re serving during critical transactions. While not as extensive as traditional banking’s know-your-customer protocols, casinos must collect and verify customer information — name, birth date, address, and SSN — whenever filing CTRs or SARs or establishing certain accounts. This extends to monitoring gambling patterns for suspicious patterns.
4. Recordkeeping requirements— Rules around keeping records create the documentation foundation for compliance. Casinos must maintain all CTRs, SARs, supporting documentation, account records, negotiable instrument logs, and gaming activity records for five years in organized, accessible formats. Without robust recordkeeping systems, casinos risk missing reportable transactions or a failure to document suspicious activity.
Together, these four interconnected requirements create a comprehensive surveillance network, ensuring casinos serve as vigilant gatekeepers against money laundering while maintaining the integrity of their operations and supporting law enforcement investigations.
Public enforcement
SARs and CTRs are the backbone of Title 31 enforcement. Regulators use them to assess casino activity and compliance — and when reporting lapses, enforcement follows. Casinos that neglect filings or run weak AML programs face fines and mandated overhauls, while those with strong reporting and internal controls can largely avoid penalties.
The stark disparity between SAR filings and enforcement actions reveals a troubling enforcement gap. Between 2020 and 2024, financial institutions filed tens of thousands of SARs annually, yet only two enforcement actions were completed during this entire period. This represents an enforcement rate that is virtually non-existant.
This enforcement deficit becomes even more striking when viewed historically. As recently as 2000, fewer than 20 SARs were filed annually. Despite this dramatic 1,000-fold increase in reporting over two decades, enforcement actions have remained stagnant.
Indeed, the numbers tell a clear story: The current system generates massive volumes of reports but delivers minimal accountability. This, in turn, undermines the entire purpose of the SARs system and calls into question whether these reporting requirements are achieving their intended deterrent effect.
Enforcement revived in 2024, and the AML Act of 2020 also has raised expectations and risks. All casinos — large or small — must treat BSA compliance as core duty. That means casinos need to file accurate, timely CTRs; investigate and report suspicious activity via SARs; and then act on those insights to mitigate risk. Recent cases — from suppressed SARs to absent AML programs — show that failures are costly and reputationally damaging.
SARs and CTRs are the backbone of Title 31 enforcement. Regulators use them to assess casino activity and compliance — and when reporting lapses, enforcement follows.
Casinos have incurred multi-million-dollar fines for serious compliance violations, including deliberately failing to maintain AML programs, ignoring BSA requirements, and neglecting to report suspicious transactions. Additional penalties have been imposed for persistent AML deficiencies and the use of misleading compliance policies. Many of these violations occurred within some casinos over multiple years, demonstrating systemic, long-term compliance failures rather than isolated incidents.
These patterns reveal that the problems extend far beyond simple administrative mistakes. Instead, they represent fundamental breakdowns in comprehensive compliance programs — failures that can only be detected and addressed through extensive data analysis using information that must come directly from the casinos themselves.
Effective filings of SARs and CTRs serve as a double-edged sword: They not only fulfill a critical regulatory obligation but also act as a barometer of a casino’s commitment to compliance. When done well, these filings protect the institution from potential sanctions and reputational damage. Conversely, poor execution can lead to severe penalties and, more alarmingly, enable illicit activities.
The requirements are straightforward. Casino operators need to prioritize compliance investments, thoroughly know their customers, submit accurate reports, and cultivate a culture that encourages the identification of suspicious transactions. The consequences of non-compliance are steep, both financially and in terms of facilitating crime.
As FinCEN underscores, a robust compliance framework is essential to maintaining the integrity of the financial system. By embracing this responsibility, casinos can establish a strong foundation for regulatory adherence — and those that fail to do so can expect rigorous enforcement action.
You can find out more about how businesses, like casinos, are managing the threat of fraud here
